Supreme Court rejects plea against restrictions on Christian missionaries entering Chhattisgarh tribal villages

The Supreme Court on Monday dismissed a plea challenging restrictions imposed in certain tribal villages in Chhattisgarh on the entry of Christian missionaries and pastors [Digbal Tandi vs. State of Chhattisgarh & Ors.].

A bench of Justices Vikram Nath and Sandeep Mehta upheld a High Court order that had made broad observations about religious conversions allegedly carried out through “inducement” and “manipulation,” and the impact of such conversions on social harmony and tribal cultural identity.

“Religious conversion has long been a sensitive issue in India’s socio-political landscape. Among the various forms of conversion, those allegedly carried out by Christian missionaries among poor and illiterate tribal and rural populations have generated particular controversy. While the Constitution guarantees every citizen the freedom to profess, practice, and propagate religion, the misuse of this liberty through coercion, inducement, or deception has become a matter of grave concern. The phenomenon of mass or motivated conversions not only disturbs social harmony but also challenges the cultural identity of indigenous communities," the High Court had noted.

The case arose from a Chhattisgarh High Court order that had rejected a plea concerning resolutions passed by certain Gram Sabhas in tribal areas allegedly banning the entry of Christian pastors and converted tribals into villages.

Hoardings had reportedly been put up in some villages stating that entry of pastors and priests was prohibited under the Panchayat (Extension to Scheduled Areas) Act.

The petitioner before the High Court had contended that such resolutions violated the fundamental rights of Christians under Articles 14, 19(1)(d) and 25 of the Constitution.

It was also argued that Christian tribals were being denied burial rights, subjected to social boycott and forced displacement, and that communal tension was being fuelled in the region.

The High Court rejected the plea and asked the petitioners to approach the individual Gram Sabhas. However, while doing so, it made detailed observations on religious conversions by Christian missionaries.

"Missionary activity in India dates back to the colonial period, when Christian organizations established schools, hospitals, and welfare institutions. Initially, these efforts were directed at social upliftment, literacy, and health care. However, over time, some missionary groups began using these platforms as avenues for proselytization. Among economically and socially deprived sections, especially Scheduled Tribes and Scheduled Castes, this led to gradual religious conversion under the promise of better livelihoods, education, equality. What was once seen as service became, in many cases, a subtle instrument of religious expansion. The menace arises when conversion ceases to be a matter of personal faith and becomes a result of inducement, manipulation, or exploitation of vulnerability. In remote tribal belts, missionaries are often accused of targeting illiterate and impoverished families, offering them monetary aid, free education, medical care, or employment in exchange for conversion. Such practices distort the spirit of voluntary faith and amount to cultural coercion. This process has also led to deep social divisions within tribal communities. Tribals converted to Christianity often adopt new cultural practices, distancing themselves from traditional rituals and communal festivals. As a result, villages become polarized, leading to tension, social boycotts, and sometimes even violent clashes," the High Court said.

It noted that Christian missionaries are particularly controversial for misusing the right to propagate religion by coercing, inducing, and manipulating tribal communities.

These remarks formed part of the High Court’s reasoning and were subsequently challenged before the Supreme Court.

Before the top Court, Senior Advocate Colin Gonsalves, appearing for the petitioner, argued that the High Court had made sweeping remarks without any supporting material.

He submitted that over 700 attacks on pastors during prayer meetings were already pending consideration before the Supreme Court in another case. He also pointed to instances where tribals converted to Christianity were not allowed to bury their dead in their villages.

"In Chhattisgarh there is a custom. First case was 700 attacks on Pastors during prayer meetings. That is pending before court no. 1. The second case is where tribals were converted to Christianity were not allowed to be buried in the village. There was a difference of opinion on that. There’s a third petition coming up on Wednesday before this court. Where the tribals who are buried in the village, their bodies are being dug out. There is not a single conviction under conversion law for the last 10 years in Chhattisgarh. Look at how the High Court goes," Gonsalves said.

He reiterated that the High Court had delivered a long commentary on Christian conversions without any factual basis.

Solicitor General Tushar Mehta, appearing for the State, submitted that Gonsalves was making additional assertions before the top court which were not part of the proceedings before the High Court.

He contended that the case before the High Court was limited to removal of the hoardings for which the petitioners were directed to approach the Gram Sabhas of the concerned villages.

The Court concurred with Mehta.

“Mr. Gonsalves, please see the writ petition before the high court and the relief claimed. You have been asked to go the Gram Sabha,” the Court said.

Gonsalves responded by stating that the High Court’s remarks had a wider impact.

“You can’t stop me from doing my Sunday prayer meeting. And the High Court says it’s not unconstitutional,” he said.

The Court however, was not persuaded to interfere and dismissed the petition.

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